Effective date: 1 October 2025

1) Purpose and scope

This policy sets out Intaleaf’s commitment to conduct business ethically and in compliance with the UK Bribery Act 2010 and all applicable anti-corruption laws where we operate. It applies to all employees, officers, contractors, intermediaries, agents, and suppliers acting on our behalf.

2) Our principles

• Zero tolerance of bribery or corruption in any form.
• No facilitation payments, kickbacks or secret commissions.
• No bribes to or through third parties.
• Heightened caution with public officials (e.g., regulators, customs, healthcare bodies).
• Accurate books and records; no off-book accounts.
• Third-party due diligence proportionate to risk.

3) What is a bribe?

Offering, promising, giving, requesting or accepting a financial or other advantage to improperly influence an action or decision. This includes cash, gifts, hospitality, discounts, services, jobs/internships, charitable donations used improperly, or anything of value.

4) Gifts, hospitality & expenses

Modest, transparent, and never to secure an improper advantage.

Pre-approval required if any of the following apply:

• Offered to a public official, regardless of value.
• Exceeds £100 per person per occasion or £300 cumulative per person per year.
• Could be perceived as lavish, frequent, or timed around a decision.

Record all gifts/hospitality in the Gifts & Hospitality Register maintained by Compliance.

Travel/expenses for third parties must have legitimate business purpose, be reasonable, and be pre-approved.

5) Charitable donations & sponsorships

Must be transparent, pre-approved, and not a condition for business. Political donations are prohibited unless approved by the Board and lawful.

6) Interactions with public officials

Given our regulated sector (Home Office, MHRA, customs), special rules apply: No gifts, hospitality or payments to public officials without prior written approval from Compliance. All interactions must be lawful, documented, and for legitimate business purposes only.

7) Third parties & suppliers

• Perform risk-based due diligence (ownership, reputation, sanctions, conflicts).
• Put ABC clauses in contracts (right to audit, termination for breach).
• Pay only transparent, reasonable fees against valid invoices; no cash equivalents.

8) Books, records & controls

Keep complete, accurate financial records and supporting documentation. Never conceal or misdescribe payments. Use approved channels for payments; segregation of duties applies.

9) Reporting concerns

Report immediately to compliance@intaleaf.com. Concerns may be raised confidentially. Retaliation against good-faith reporters is prohibited.

10) Training & responsibilities

All staff must complete induction and periodic ABC training.
Managers must reinforce this policy and escalate concerns.
Compliance maintains the Gifts & Hospitality Register, oversees due diligence, and performs periodic risk assessments.

11) Breach consequences

Breaches may result in disciplinary action, termination of contracts, and reporting to authorities. Individuals and the company may face criminal and civil penalties.

12) Review

This policy is reviewed at least annually or following material legal or operational changes.

Contact: compliance@intaleaf.com